From the Insolvency Law Committee Bankruptcy e-Bulletin:
A California appellate court has held that a mortgagor may recover for intentional infliction of emotional distress from a mortgagee that falsely promised to modify her loan but then proceeded to foreclose. [Ragland vs. U.S. Bank, N.A., 2012 Westlaw – – (Cal.App.)]
I’ll post the cite as soon as I get it.
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